The End of “Everything = G2025”? What RHCs Should Know About a Potential Telehealth Billing Shift
For years, Rural Health Clinics (RHCs) have operated in a relatively straightforward Medicare telehealth billing environment:
Telehealth encounter = G2025
Whether the visit involved a simple follow-up, chronic disease management, medication adjustment, or more complex clinical decision-making, many Medicare telehealth encounters ultimately flowed through the same reimbursement pathway.
That simplicity may eventually be changing.
Industry organizations, including the National Association of Rural Health Clinics (NARHC), have discussed an anticipated operational transition that could move RHCs away from the “everything = G2025” methodology and toward reporting the actual CPT/HCPCS service performed during the telehealth encounter.
To be clear: current CMS guidance still supports G2025 billing, and organizations should continue following existing Medicare requirements unless and until CMS finalizes a different methodology.
However, this is an important development for RHC leadership, coding, compliance, and revenue cycle teams to begin monitoring now.
Where We Are Today: The G2025 Model
Currently, Medicare RHC telehealth services are generally billed using HCPCS G2025, which represents payment for distant-site telehealth services furnished by an RHC or FQHC.
Importantly, these services are not reimbursed at the traditional RHC AIR (All-Inclusive Rate). Instead, telehealth is paid using a national payment methodology, approximately $97.53 in CY 2026, regardless of the clinic’s AIR.
Operationally, this means:
- Telehealth reimbursement is largely standardized
- Claims may not fully reflect the complexity or intensity of the actual service provided
- A straightforward follow-up visit and a more medically complex encounter may appear operationally similar from a billing perspective
- Telehealth reporting and analytics can be limited because all encounters are grouped under a single payment methodology
For many RHCs, this structure has simplified billing workflows. But it has also created challenges related to visibility into provider work, service mix, telehealth utilization, and reimbursement modeling.
What Could Change?
The anticipated transition would move RHCs away from billing a single telehealth code (G2025) and toward reporting the underlying CPT/HCPCS service furnished during the encounter.
In practical terms, this could look like:
Today:
Telehealth diabetes follow-up → G2025
Potential Future State:
Telehealth diabetes follow-up meeting low MDM requirements → 99213 (telehealth methodology applied)
Or:
Today:
Virtual Annual Wellness Visit → G2025
Potential Future State:
Virtual Annual Wellness Visit → Underlying preventive service reported
In short, Medicare telehealth claims may begin reflecting what was actually performed, rather than routing nearly all encounters through a single telehealth code.
For many organizations, this would represent a significant operational change.
Why This Matters
At first glance, this may sound like a billing change only.
It is not.
If implemented, this type of transition could impact:
- Provider documentation
- Coding workflows
- Audit defensibility
- Revenue cycle processes
- Charge master configuration
- Reporting and analytics
- Reimbursement forecasting
1. Documentation Expectations
One area organizations should monitor closely is how documentation expectations could evolve if Medicare telehealth billing transitions from a single telehealth code (G2025) to the underlying CPT/HCPCS service performed.
In reality, many RHC providers are already documenting telehealth visits similarly to traditional E/M encounters, and organizations frequently use note templates that support problem assessment, medication review, assessment/plan, and medical necessity. In many clinics, these encounters already resemble office E/M documentation.
However, the operational shift may be less about changing how providers document and more about how documentation is evaluated and defended.
Today, under the G2025 methodology, organizations are generally supporting a medically necessary telehealth encounter.
If reimbursement transitions to the actual CPT/HCPCS service performed (e.g., 99213, 99214, preventive, behavioral health), documentation may face increased scrutiny related to code-level support, similar to traditional professional E/M auditing.
Organizations may need to more consistently demonstrate:
- Problems addressed during the encounter
- Medical decision making (MDM) complexity
- Prescription drug management or treatment decisions
- Chronic condition complexity or exacerbation
- Data reviewed or interpreted (when applicable)
- Time documentation (if billing by time)
- Medical necessity supporting the level of service
In other words, for many RHCs this may not represent a dramatic documentation overhaul — but rather a shift toward greater specificity, consistency, and audit defensibility tied to the actual CPT/HCPCS service billed.
2. Revenue Cycle & Operational Impact
If underlying CPT/HCPCS reporting becomes required, organizations may need to revisit:
- Charge description master (CDM) configuration
- Telehealth billing workflows
- Modifier logic
- Internal edits and claim validation
- Coding education
- Audit strategies
- Reporting methodologies
Organizations may also need to reconsider how telehealth productivity and reimbursement are tracked.
One important point:
This anticipated change should not automatically be interpreted as a return to AIR payment methodology.
Based on current CMS direction, a more likely outcome may be service-specific reimbursement using a PFS/non-facility methodology, rather than traditional AIR reimbursement.
That distinction will matter significantly for budgeting and reimbursement modeling.
3. Provider Education
If the transition occurs, provider education will likely become increasingly important.
Topics may include:
- Telehealth documentation expectations
- Medical decision- making support
- Time-based coding requirements
- Audio-only documentation
- Telehealth modifier requirements
- Code-level audit defensibility
Organizations that proactively educate providers may be better positioned to avoid denials, downcoding, and audit risk.
What Should RHCs Do Now?
At this stage, organizations should avoid overreacting — but they also should not ignore the discussion.
Practical next steps include:
- Monitor CMS final rulemaking and MLN communications
- Evaluate current telehealth documentation consistency
- Assess provider readiness for CPT/HCPCS-level telehealth reporting
- Review telehealth templates for MDM specificity and medical necessity
- Prepare coding, billing, and compliance teams for potential workflow changes
- Begin conversations regarding reimbursement forecasting and reporting impact
Final Thoughts
For years, Medicare RHC telehealth has largely existed in a “one code fits all” environment.
If the anticipated transition occurs, telehealth may begin functioning much more like traditional professional coding — potentially improving service visibility and reporting, while also increasing expectations around documentation specificity and code-level support.
For many RHCs, the strongest preparation strategy is not panic — it is readiness.
Because while G2025 may still be the rule today, the telehealth billing conversation in the RHC space appears to be evolving.
Disclaimer: Current CMS guidance continues to support G2025 billing for Medicare RHC telehealth. The transition discussed above should be considered anticipated/expected based on industry communications and should be monitored closely for final CMS implementation guidance.